Sugarloaf Alliance

October 12, 2025

Frederick County Planning Commission
Re: CDI Overlay Comprehensive Plan Amendment

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Planning Commissioners:

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Contained in the comments of the Maryland Department of Planning is a suggestion that the CDI Plan amendment contain reference to the State’s newly adopted “8 Planning Principles.” To address this suggestion staff has drafted a narrative, which includes “Plan Consistency – What the LFMP Says.”

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The proposed narrative makes many references to parts of Livable Frederick [LFMP]. Surprisingly, there is no mention in the narrative of the bulk of the material in the Eastalco Growth Area section of LFMP. In fact, nowhere in the proposed CDI CDI-OZ Comprehensive Plan Amendment is there any mention of the explicit requirements in LFMP for future planning and development in and around the Eastalco Growth Area (LFMP Pages 43-44). The explicit, and unique requirements listed in LFMP (pages 43-44) have not been addressed during this planning process.

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For the reasons stated below, we strongly suggest that the CDI Overlay map be drawn to match the existing Eastalco Growth Area. Using the current growth area is the best way to take a measured step forward for the data center industry while avoiding many of the policy conflicts associated with an enlarged growth area.

 

The amendment to Livable Frederick regarding development of the Eastalco Growth Area

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Several of you were directly involved in the drafting and passage of the Livable Frederick Master Plan (LFMP) and you may recall the distress caused by the “New Town” at Eastalco. In 2019, following years of work, the LFMP was presented to the County Council for legislative action.  Contained in the draft LFMP was a description of a proposed “new town” in the Eastalco area.

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“New Town

A major focal point for new development is identified in the area surrounding the decommissioned “Eastalco” site. ... This area is currently the largest concentration of industrial land in the county. However, it presents significant potential for growth in the

form of a transit oriented, mixed-use development “new town” that includes significant employment and industrial uses.” (1)

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Public opposition to this part of the draft LFMP was intense. As a direct result of numerous community letters and statements at an hours long public hearing, Council Members Donald, McKay, and Hagen crafted an amendment to LFMP to address the people’s concerns. All seven Council Members voiced support for the amendment, including the now County Executive and three current Council Members. (2) The amendment passed unanimously.

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The intent of the legislators with this amendment is clear from the content of the meeting. We urge anyone unsure as to the reasons for the amendment or the Council’s intent for future interpretation to watch the 40 minutes of discussion and the vote. The meeting can be viewed beginning at the 40:00 mark here:

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https://frederick.granicus.com/MediaPlayer.php?view_id=10&clip_id=7041&meta_id=98510

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Mr. Donald’s amendment set out a wide range of studies and community engagements needed as part of any planning process for the future of the Eastalco Growth Area. The relevant part of Livable Frederick now reads:

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“Eastalco Growth Area

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“A continuing focal point for development is identified in the area surrounding the decommissioned “Eastalco” site ... including, but not limited to, land holdings of the former Alcoa aluminum refinery and production plant ... This area is currently the largest concentration of undeveloped land in the county zoned for general and/or light industrial development and presents a unique opportunity for future development.

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“The opportunity for future development at points along this corridor – including the Eastalco site, South Frederick (13, 15), and Point of Rocks (16) – will be assessed and considered carefully during the development of small area plans for each of these places. ...

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“For the Eastalco Growth Area, overarching development issues and opportunities would require a detailed assessment of the following elements as part of a future community planning effort, including:

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• A community outreach component that will include a citizens advisory group or similar entity to ensure broad community engagement;

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• A preservation component to include a review of historic sites and archaeological resources, viewsheds and cultural characteristics (identification, documentation, and preservation when appropriate), including special consideration of structures and sites associated with Charles Carroll of Carrollton Manor;

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• An infrastructure component that identifies the timing and funding of public facilities (including roads and schools) necessary to support the efficient development of the designated growth area;

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• A comprehensive study to address MARC system access and expandability with input from Maryland Transit Authority, County Transit, and CSX;

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• A green infrastructure component that includes a detailed review of environmental systems and resources (hydrology, forests, habitat assessment), and that integrates the built environment to the natural edges, through the placement and programming of open space and additional preservation areas;

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• An agricultural preservation component that examines options to encourage preservation of the valuable farmland at the site, as well as in the surrounding Priority Preservation Area;

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• A thorough, transparent and open study of industrial site contamination and subsequent post-industrial remediation and monitoring efforts, in consultation with Maryland Department of the Environment and the Environmental Protection Agency;

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• An assessment of the potential land use mix, which could include business, retail, residential, industrial, agricultural, open space, recreational, and institutional uses, for the growth area, including physical design, neighborhood impacts, public facility adequacy, comparative analysis of alternate land use scenarios, unique opportunities to address countywide planning challenges, and development feasibility;

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• And finally, a thorough examination of how this existing growth area fits into the larger planning context for Frederick County, addressing countywide growth projections, current and future transportation challenges, and community efforts to plan effectively, consistently, and in a coordinated manner, for the Frederick County of tomorrow.”

 

(Livable Frederick Master Plan, September 3, 2019. pp 43-44. Emphasis added)

 

While some of the requirements of this part of Livable Frederick apply less to a new data center industrial zone than to a ‘new town’, the language on needed analysis and community engagement is as relevant today as it was in 2019. Every planning or zoning action undertaken by Frederick County makes reference to Livable Frederick. Even the ‘Critical Digital Infrastructure Overlay Zone’ staff report carries the Livable Frederick logo. Yet the information packet contains no reference to the Eastalco Growth Area section of LFMP (pages 43-44).

 

On June 15, 2022, during discussion of a future Eastalco area planning activity, staff told the Commission:

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We “need to circle back as a county and look at the impacts and implications of the development that’s happening [at Eastalco] now because it was not anticipated in 2019. And it is at a scale and type of development that we were not thinking about in 2019. So we need to get back there to think about the existing communities that border the area. Is it an area that is ultimately going to expand? How is it going to grow and evolve and change over time? So that’s something that I think we need to put on our road map.” (3)

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In 2019 with the draft LFMP, “what was ultimately agreed to is we called it a Growth Area and we kinda stripped away some of the qualifying language ... the details ... with the promise ... I think it’s page 43, there’s like a half a page ... that talks about what we need to do when we go back to [the Eastalco Growth Area] and reconsider it. But in the interim Quantum Loophole [happened]. That’s why I think there’s an imperative to act there and kind of take care of it. The [Livable Frederick Master] Plan makes promises to the community. It says it will be engaged in a community planning process, will anticipate what the impacts are of development and will work with the community. And we didn’t get a chance to do that. And I think it’s important that we do that.”

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During the May 27, 2025, Council meeting on the Overlay, Council Member McKay, specifically called out the language in LFMP relative to master plan changes at the Eastalco Growth Area.

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“In looking through this, the Comp Plan amendment process in particular, you know, there was specific language that was inserted into the Livable Frederick Master Plan about this area that includes a lot of requirements for how this kind of consideration and process would go and the things that we would need to do. So are you planning this consistent with that language, in LFMP? ... We're talking about now an overlay and not just the QL development, an overlay that could involve a lot more land. I strongly urge you to not give that language short shrift, because it created an expectation in that community of involvement and of transparency, of interaction. And I mean, I would start with, you know, listing those, you know, those elements and how they overlay into what would currently be the normal Comp Plan process in terms of outreach, and where do they differ, and see if you can find ways to bridge those differences, because that's what the people are expecting out of this.” (4)

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To be clear, none of the Livable Frederick Master Plan requisite actions governing development of the Eastalco Growth Area or its expansion to surrounding lands have been undertaken. Put another way, the proposed CDI Overlay Map is fundamentally inconsistent with the Livable Frederick Master Plan. 

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The path forward

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Given the clear language of LFMP regarding planning for the Eastalco Growth Area, and the equally clear, unanimous legislative intent of the County Council in 2019, there are only two real options for the Planning Commission.

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Either the LFMP-required actions are initiated as soon as possible and the overlay map is paused to allow for additional study and community engagement, or the Commission requests that the County Executive begin the process of amending Livable Frederick to remove the requirements on pages 43 and 44. Simply rushing forward with a de facto Eastalco small area plan is both unnecessary and inflammatory.

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A slight change of tactic offers a third option. If the CDI Overlay is applied to only the existing Eastalco Growth Area, there is no need to change the growth boundary and no need to comply with the requirements of LFMP. This approach also has the virtue of avoiding the policy conflicts with the county’s long-held agricultural and land preservation programs.

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The CDI Overlay map should define a single, compact and contiguous area within the existing Eastalco Growth Area.

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The Eastalco Growth Area is the site of current data center construction. Almost all of this land is currently zoned industrial and is in the most appropriate area for data center development. We think allowing data center development to sprawl beyond the current growth area is needlessly problematic.

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Thank you, Sugarloaf Alliance

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LINK to Livable Frederick Master Plan

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(1) Council Member Donald (District 1), AMENDMENT 53 to Livable Frederick Master Plan. Introduction Date: August 27, 2019.
(2) Frederick County Council meeting August 27, 2019, at 40:00.

See https://frederick.granicus.com/MediaPlayer.php?view_id=10&clip_id=7041&meta_id=98510

(3) 3 Frederick County Planning Commission, June 15, 2022, at 3:03:10.

(4) Frederick County Council meeting May 27, 2025, at 2:03:00.